Faculty and staff members who conduct internationally sponsored projects under the University have an important public and personal responsibility to manage those projects carefully. For general questions please contact the Office of Research Services.
For specific international operations considerations, review the Research Regulations and contact GSS if you have additional questions.
New Policy: 2142
Notice regarding US Gov't Policy Against Human Trafficking and Forced Labor
The U.S. government has adopted a policy prohibiting human trafficking, sex trafficking, forced labor, and trafficking-related activities. As a recipient of federal funds from grants, cooperative agreements, and contracts (collectively, “awards”), the University of Pennsylvania is obligated to inform its employees, agents, independent contractors and subrecipients performing awards, regarding the U.S. government’s policy. We advise all federally funded researchers to review the Policy 2142.
The University of Pennsylvania opposes human trafficking, sex trafficking, and forced labor, which are inherently harmful and contrary to the University’s core values, and which may violate applicable foreign, U.S., state, and/or local laws.
OFAC Sanction Programs and Country Information
The Office of Foreign Assets Control (OFAC), under the U.S. Department of the Treasury, has a list of Sanction countries with assets and trade restrictions. Additional documentation and licenses may be required in order to travel to these countries. Please visit OFAC for more details on sanction program details by country.
Global Anti-Bribery & Corruption
The University may be subject to numerous anti-bribery laws and regulations when conducting international activity both inside and outside the US. As Penn increases its global outreach and engagement, it increases its exposure to Global Anti-Bribery & Corruption Laws. If your activity takes you abroad, or if you are engaged in activity with foreign entities and individuals, you are responsible for adhering to US law and also any anti-bribery and corruptions laws that exist in the country in which you are operating. For example:
- UK Bribery Act
- China Anti-Unfair Competition Law
- -- NEW: Draft of Revised China Anti-Unfair Competition Law (a/o March 2016)
- Brazil Clean Company Act
- Canada Corruption of Foreign Public Officials Act
Enforced jointly by the SEC and the Department of Justice, the FCPA is the US Law that regulates anti-bribery and corruption with overseas entities. Follow the FCPA link above to make yourself aware of how to be compliant.